Within its Human Rights Statement, SunPower has adopted requirements of the CTSCA as part of our due diligence. Below is a disclosure of how we practice those requirements:

Product Supply Chain Human Trafficking Risk Assessment: SunPower conducts human trafficking risk assessment of its supply chain through several steps. First, we look for adequate supplier management systems over human rights in our pre-qualification audit of suppliers. We provide notice to suppliers of our human trafficking concerns in our supplier guidelines, and note which suppliers sign those guidelines. We also conduct a yearly supplier survey that asks directly about human trafficking precautions. And our trained commodity managers continuously review the capabilities of and news about suppliers. We then examine other public information, including the US State Department’s list of locations at high risk for human trafficking, and concerns about specific industries. Based upon our review of a given supplier we may have suppliers create action plans to mitigate risk. Such analysis is conducted internally through our supply chain organization without a third-party organization or company.

Supplier Audits: SunPower retains the right to conduct audits of suppliers to evaluate suppliers’ compliance with SunPower’s standards regarding human trafficking and slavery in supply chains. This language is in our supplier guidelines. SunPower prioritizes auditing suppliers deemed high risk. Because many of our suppliers operate in similar countries, we pay particular attention to types of industry and types of labor employed. If such audits are conducted, SunPower will conduct a preliminary audit of the supplier and, if warranted, a third-party audit firm may be retained to do a follow-up audit. Audits will likely be announced in advance.

Supplier Certification: SunPower requires its first tier direct suppliers to sign an agreement verifying that they are not engaged, either directly or indirectly, in human trafficking or slavery, this document is SunPower’s Commitment to the Elimination of Human Trafficking and Slavery. The Commitment requires suppliers, in all of their activities, to operate in full compliance with laws, rules, and regulations applicable to human trafficking and slavery in the countries in which they operate, as well as any other related applicable laws. SunPower reminds its suppliers to go beyond legal compliance and draw upon internationally recognized standards to ensure that human trafficking and slavery do not occur in SunPower's direct supply chain. SunPower asks our direct suppliers to undertake necessary measures to ensure that their own suppliers do not engage in human trafficking and slavery.

Accountability & Management Systems: In addition to having the right to audit suppliers to evaluate their compliance with SunPower’s standards regarding human trafficking and slavery, SunPower has also explicitly stated in its contracts with suppliers and in SunPower’s Commitment to the Elimination of Human Trafficking and Slavery that any violations of SunPower’s standards regarding human trafficking and slavery may result in the termination of SunPower’s business relationship with a supplier. Supply Chain Operations has responsibility for disseminating knowledge of human trafficking and slavery to suppliers, while all SunPower employees have the responsibility for identifying possible infractions.

SunPower holds its employees to equally high standards. Human rights violations by our employees are unacceptable and impermissible pursuant to the principles and values embodied in our Code of Business Conduct and Ethics (“Code of Conduct”). An employee’s conduct (or failure to act), which is inconsistent with the principles and values embraced in SunPower’s Code of Conduct will result in disciplinary action, up to and including, termination of employment. All employees are made aware of the internal compliance and ethics hotline.

Anti-Human Trafficking Training and Communications: SunPower offers in-person training covering human trafficking to staff who manage suppliers, and avails an online version of the course to all staff. The training not only covers the substance of human trafficking and how to identify, but also how to assess risk. SunPower reviews human trafficking concerns in the context of its supply chain with executive staff through the Sustainability Council and with employees who manage suppliers.